3090-0163_JUSTIFICATION_2008_updated_6-27-08

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
3090-0163, INFORMATION SPECIFIC TO A CONTRACT OR
CONTRACTING ACTION (NOT REQUIRED BY REGULATION)

A. Justification
1. Explain the circumstances that make the collection of information necessary. Identify
any legal or administrative requirements that necessitate the collection. Attach a copy of
the appropriate section of each statute and regulation mandating or authorizing the
collection of information.
The General Services Administration (GSA) has various mission responsibilities related to the
acquisition and provision of supplies, transportation, ADP, telecommunications, real property
management, and disposal of real and personal property. These mission responsibilities generate
requirements that are realized through the solicitation and award of public contracts. Individual
solicitations and resulting contracts may impose unique information collection/reporting
requirements on contractors, not required by regulation, but necessary to evaluate particular
program accomplishments and measure success in meeting special program objectives. It also
includes collecting information that is central to contracting with up to 2,000 hotels that provide
lodging for Federal travelers.
In addition, the Office of Small Business Utilization (OSBU) has an electronic form, Disaster
and Emergency Operations Vendor Profile Form (GSA Form 3685). This form can be accessed
at www.gsa.gov/disastersupportform. The form is to be completed by all vendors interested in
GSA contracting opportunities during times of natural or environmental disasters and national or
civil emergencies. Vendors that supply products or services that may be needed to support this
effort and who wish to be considered as potential sources of supply may be identified in the
Disaster and Emergency Operations Vendor Profile Database. There are currently 1,519
vendors in the database.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for
a new collection, indicate the actual use the agency has made of the information received
from the current collection.
Contracting officers use the information to evaluate and monitor unique contract requirements to
meet specialized program objectives. Such information is also necessary for program managers
to make informed decisions germane to those specialized areas.
The Disaster and Emergency Operations Vendor Profile Database is in Lotus Notes format. It
can only be accessed by the National Office SBU staff, Regional Small Business Utilization
Centers, and Small Business Technical Advisors in National Office FAS and National Office
PBS. There are currently 1,519 vendors in the database. Among other market research methods
in FAR Part 10, contracting officer may contact Regional GSA Offices of Small Business
Utilization to assist in obtaining information regarding local small business firms capable of
providing products or services during times of natural or environmental disasters and national or
civil emergencies.

1 of 6
2008 Justification

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
3090-0163, INFORMATION SPECIFIC TO A CONTRACT OR
CONTRACTING ACTION (NOT REQUIRED BY REGULATION)
3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological collection techniques or other
forms of information technology, e.g., permitting electronic submission of responses, and
the basis for the decision for adopting this means of collection. Also describe any
consideration of using information technology to reduce burden.
We use improved information technology to the maximum extent practicable. Where both the
General Services Administration and contractors are capable of electronic interchange, the
contractors may submit information requirements electronically.
The Disaster and Emergency Operations Vendor Profile Form (GSA Form 3685) is only an
electronic form accessible at www.gsa.gov/disastersupportform.
4. Describe efforts to identify duplication. Show specifically why any similar information
already available cannot be used or modified for use for the purposes described in Item 2
above.
As indicated in 1 above, the requirements are not mandated by regulation and usually are
germane to a particular solicitation or resulting contract(s).
The information collected on GSA Form 3685 may be available on the Central Contractor
Registry (CCR); however, the data is not readily available, or easily searchable . The GSA data
base places vendor information related to disaster and emergency products and services at the
ready for GSA in a central database that easily searchable. The database should only include
potential sources for meeting agency needs during disasters and emergencies. This is important
because GSA has a number of different roles in preparedness, response and recovery in disaster
or emergency situations. On a national level, GSA participates in governmentwide disaster
preparedness and assistance through the National Response Plan, which is the federal
government’s unified approach to dealing with natural or manmade incidents.
5. If the collection of information impacts small businesses or other small entities (item 5 of
OMB 83-I), describe any methods used to minimize burden.
Burdens usually apply equally to large and small businesses that want to contract with GSA.
Burden is kept to the minimum necessary to meet the specific objectives of a solicitation or
contract.
As indicated in 4 above, the Disaster and Emergency Operations Vendor Profile Form (GSA
Form 3685) is only an electronic form accessible at www.gsa.gov/disastersupportform.
6. Describe the consequence to Federal program or policy activities if the collection is not
conducted or is conducted less frequently, as well as any technical or legal obstacles to
reducing burden.
2 of 6
2008 Justification

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
3090-0163, INFORMATION SPECIFIC TO A CONTRACT OR
CONTRACTING ACTION (NOT REQUIRED BY REGULATION)

Specific program objectives would not be met or performance could not be measured.
GSA is lead on one of the 15 Emergency Support Function under the National Response Plan.
GSA is responsible for providing centralized logistics management and resource support to
Federal State and state governments. GSA support includes facility space, office supplies, office
furniture, contracting services, and emergency relief supplies. Readily available information will
assist GSA fulfill its responsibility as the lead for one of the Emergency Support Functions.
Without the readily information centrally located internal to GSA, valuable time may be lost in
meeting the needs of Federal State or local governments requiring support.
7. Explain any special circumstances that would cause an information collection to be
conducted in a manner requiring respondents to—
•
•
•
•
•
•
•

•

Report information to the agency more often than quarterly;
Prepare a written response to a collection of information in fewer than 30 days after
receipt of it;
Submit more than an original and 2 copies of any document;
Retain records, other than health, medical, government contracts, grant-in-aid, or
tax records, for more than 3 years;
In connection with a statistical survey, that is not designed to produce valid, reliable
results that can be generalized to the universe of study;
Require the use of a statistical classification that has not been reviewed and
approved by OMB;
Include a pledge of confidentiality that is not supported by authority established in
statute or regulation, that is not supported by disclosure and data security policies
that are consistent with the pledge, or which unnecessarily impedes sharing of data
with other agencies for compatible confidential use; or
Submit proprietary trade secrets, or other confidential information unless the
agency can demonstrate that it has instituted procedures to protect the
information’s confidentiality to the extent permitted by law.

Upon occasion due to urgency of a procurement or when conducting an acquisition of
commercial items, respondents may be requested to prepare a written response to a collection of
information (response to solicitation for offers) in fewer than 30 days after receipt of the request.
Respondents may also be required by contract to submit information on a monthly basis.
The Disaster and Emergency Operations Vendor Profile Form (GSA Form 3685) is an electronic
form that can be completed once. Updates may be required based on expansion of the vendor’s
product line or services; however, GSA does require an update. The form is voluntary. The
form is for information purposes and does not imply any contract or promise of business.

3 of 6
2008 Justification

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
3090-0163, INFORMATION SPECIFIC TO A CONTRACT OR
CONTRACTING ACTION (NOT REQUIRED BY REGULATION)
8. If applicable, provide a copy and identify the date and page number of publication in
the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting
comments on the information collection prior to submission to OMB. Summarize public
comments received in response to that notice and describe actions taken by the agency in
response to these comments. Specifically address comments received on cost and hour
burden.
Describe efforts to consult with persons outside the agency to obtain their views on the
availability of data, frequency of collection, the clarity of instructions and recordkeeping,
disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed,
or reported. Consultation with representatives of those from whom information is to be
obtained or those who must compile records should occur at least once every 3 years – even
if the collection of information activity is the same as in prior periods. There may be
circumstances that may preclude consultation in a specific situation. These circumstances
should be explained.
A notice published in the Federal Register at 73 FR 16305, March 27, 2008 made this
requirement available to the public and requested comments. No comments were received
regarding this requirement. However, the GSA Form 3685 was not included in the Federal
Register notice.
9. Explain any decision to provide any payment or gift to respondents, other than
reenumeration of contractors or grantees.
GSA makes no such payments under this collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
Confidentiality will be provided to contractors in accordance with prudent business practices and
current regulations.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private. This justification should include the reasons why the agency considers the
questions necessary, the specific uses to be made of the information, the explanation to be
given to persons from whom the information is requested, and any steps to be taken to
obtain their consent.
No sensitive questions are involved.
12. Provide estimates of the hour burden of the collection of information. The statement
should—

4 of 6
2008 Justification

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
3090-0163, INFORMATION SPECIFIC TO A CONTRACT OR
CONTRACTING ACTION (NOT REQUIRED BY REGULATION)
•

Indicate the number of respondents, frequency of response, annual hour burden,
and an explanation of how the burden was estimated. Unless directed to do so,
agencies should not conduct special surveys to obtain information on which to base
hour burden estimates. Consultation with a sample (fewer than 10) of potential
respondents is desirable. If the hour burden on respondents is expected to vary
widely because of differences in activity, size, or complexity, show the range of
estimated hour burden, and explain the reasons for the variance. Generally,
estimates should not include burden hours for customary and usual business
practices;
• If this request for approval covers more than one form, provide separate hour
burden estimates for each form and aggregate the hour burdens in Item 13 of OMB
Form 83-I; and.
• Provide estimates of annualized cost to respondents for the hour burdens for
collections of information, identifying and using appropriate wage rate categories.
The cost of contracting out or paying outside parties for information collection
activities should not be included here. Instead, this cost should be included in Item
13.
The estimated number of respondents annually is 126,870; and responses per respondent is 1.36.
Each response requiring .399 hours for a total of 68,900 hours. Time and cost estimates are
based on professional judgment using data from the Federal procurement Data System for FY
03.
Estimated respondents/yr………………………………………..
Total Responses annually……………………………………….
Estimated hours/response……………………………………….
Estimated total burden hours…………………………………….

126,870
172,500
.399
68,900

*There are no changes based on inclusion of GSA Form 3685 under this collection number.
13. Provide an estimate for the total annual cost burden to respondents or recordkeepers
resulting from the collection of information. (Do not include the cost of any hour burden
shown in Items 12 and 14.)
• The cost estimate should be split into two components: (a) total capital and start-up
cost component (annualized over its expected useful life) and (b) a
total operation and maintenance and purchase of services component. The estimates
should take into account costs associated with generating, maintaining, and
disclosing or providing the information. Include descriptions of methods used to
estimate major cost factors including system and technology acquisition, expected
useful life of capital equipment, the discount rate(s), and the time period over which
costs will be incurred. Capital and start-up costs include, among other items,
preparations for collecting information such as purchasing computers and software;
monitoring, sampling, drilling, and testing equipment, and record storage facilities.
• If cost estimates are expected to vary widely, agencies should present ranges of cost
burdens and explain the reasons for the variance. The cost of purchasing or
5 of 6
2008 Justification

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
3090-0163, INFORMATION SPECIFIC TO A CONTRACT OR
CONTRACTING ACTION (NOT REQUIRED BY REGULATION)

•

contracting out information collection services should be a part of this cost burden
estimate. In developing cost burden estimates, agencies may consult with a sample of
respondents (fewer than 10), utilize the 60-day pre-OMB submission public
comment process and use existing economic or regulatory impact analysis associated
with the rulemaking containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or
portions thereof, made: (1) prior to October 1, 1995; (2) to achieve regulatory
compliance with requirements not associated with the information collection; (3) for
reasons other than to provide information or keep records for the Government or
(4) as part of customary and usual business or private practices.

Given the nature of the requests, reliable cost estimates are not available. Costs are captured in
burden hours as shown in paragraph 12.
14. Provide estimates of annualized costs to the Federal Government. Also, provide a
description of the method used to estimate cost, which should include qualification of
hours, operational expenses (such as equipment, overhead, printing, and support staff),
and any other expense that would not have been incurred without this collection of
information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a
single table.
Estimate of the burden hours to the Federal Government is 43,125 hours. Reviewing and
processing each response should take approximately .25 hours; the total number of responses is
estimated to be 172,500 each year. 172,500 responses x .25 hours = 43,125 hours.
The total cost to the Government is $1,725,000 (Based on the 43,125 burden hours to the
Government, using the hourly salary $40 multiplied by the total review time (43,125).
Reviewing Time/hr
Requests/year
Review Time/year
Average Cost/hr
Total Government Cost

.25 minutes/hours
172,500
43,125 minutes/hours
$40
$1,725,000

*There are no changes based on inclusion of GSA Form 3685 under this collection number.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB Form 83-I.
There is no difference between the justifications for the collection as it previously existed and as
it exists now.
16. For collections of information whose results will be published, outline plans for
tabulation and publication. Address any complex analytical techniques that will be used.
6 of 6
2008 Justification

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
3090-0163, INFORMATION SPECIFIC TO A CONTRACT OR
CONTRACTING ACTION (NOT REQUIRED BY REGULATION)
Provide the time schedule for the entire project, including beginning and ending dates of
the collection of information, completion of report, publication dates, and other actions.
Results will not be tabulated or published. Data collected will be used for internal administration
of contracts.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
GSA is not seeking such approval for this collection.
18. Explain each exception to the certification statement identified in Item 19,
“Certification for Paperwork Reduction Act Submissions”, of OMB Form 83-I.
GSA has no exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods
Statistical methods are not used in this information collection.

7 of 6
2008 Justification